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Does SHAKEN/STIR Have Your Company Shaking with Uncertainty and Fear? We Can Help

SHAKEN/STIR, the industry-led framework for call authentication, will constitute a major change to the manner in which calls are processed over the public switched telephone network (PSTN).  Against a backdrop of an angry public fed up with “robocalls,” the Federal Communications Commission in June 2019 gave wide discretion for telecommunications providers to block illegal calls, and perhaps even merely unwanted calls, by default.  In July, FCC Chairman Ajt Pai hosted a summit on the SHAKEN/STIR initiative and said that he “expects major phone companies to implement SHAKEN/STIR caller ID authentication standards this year.” Although technical experts voice caution that the standard cannot be a silver bullet for fighting robocalls, public anger and political pressure are placing extremely high expectations on the development of the standard.

Notwithstanding high expectations and pressure from the FCC, Congress and the public, the frenzied effort by the standards bodies responsible for the development of the SHAKEN/STIR compliance regime to pump out the “rules of the road,” and even some incumbent carriers seemingly jumping the gun and demanding their carrier partners/customers sign contracts and sign away their rights in the blind, the reality of the current SHAKEN/STIR compliance regime is that it remains very uncertain!  The key standards bodies working on the SHAKEN standard are the Alliance for Telecommunications Industry Solutions (ATIS), together with the Session Initiation Protocol (SIP) Forum. They are modifying the Secure Telephone Identity Revised (STIR) developed by the Internet Engineering Task Force. These groups are working to finalize SHAKEN/STIR by their self-imposed/FCC brow-beaten deadline of December 11, 2019.

There remain many outstanding issues yet to been identified, much less resolved. 

Yes, at some point, all carriers and service providers with IP capacity will need to implement SHAKEN/STIR – perhaps before they are truly ready.  The politics of stopping fraudulent calls with bad caller ID may well push the agency to adopt these rules before the industry is ready to handle them.

That’s just the reality of the situation.  So it’s understandable if your company feels lost at sea when it comes to its responsibilities and duties under the SHAKEN/STIR compliance regime.  It’s understandable if your company has questions, some of which may not have readily-available answers.  

What’s not understandable is pretending SHAKEN/STIR doesn’t exist, or that it won’t impact your company, or that your company can sit back, relax, let everyone else figure things out.  Maybe say a prayer that Staples will show up at your door and hand you the Easy Button!

Image result for easy button

No.  That’s not likely to happen.  Not given the complexity of the SHAKEN/STIR compliance regime, not given the disparity in networks that are intertwined and interconnected, not given the number of disparate “hands” telephone calls are handed off to these days.  If you haven’t noticed, the days of two cans and a string connecting caller and called party are long gone.  And at the heart of the SHAKEN/STIR compliance regime is a “Know Your Customer” style verification process, but there has to be a LOT of trust involved when Carrier #4 takes a hand-off from Carrier #3 which took the hand-off from Carrier #2… and so on and so forth.  

Sitting back and waiting, ducking one’s head in the sand, and nightly prayers… these are all approaches that are likely to be taken by many in the telecom industry.  But they aren’t recommended, because:

  1. the Easy Button isn’t on its way to your doorstep, but the SHAKEN/STIR compliance regime is coming… soon… and
  2. knowing the current foundation, tracking how issues are developing, and applying what we DO KNOW NOW to what YOU KNOW NOW about your company and its operations (its carrier partners, customers, traffic) can actually help you prepare and help you avoid or mitigate the potential damage that could be done to your company, its reputation, and its revenue sources when terminating carriers start blocking YOUR customer’s traffic, and you don’t even know why they’re doing it!

While we don’t have ALL the answers, because some things have not yet been decided (much less imagined) by those responsible for the SHAKEN/STIR compliance regime, our firm CAN HELP!  We can help get you started down the path of knowledge, understanding, and self-evaluation to ensure you are as prepared as any company can be given the current state of affairs.

Whether your company is already well-versed in these issues or needs support from the ground up, please contact Drew Clark at apc@commlawgroup.com or call 703-714-1323 to schedule a consultation or discuss your concerns.

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